Petition for Exemption, requesting relief from the FAA Modernization and

Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333

Petitioner: 

Jimmy J Carini

SKY ESTATES DRONES, LLC

229 Hillside Rd

Oak Ridge TN 37830

PETITION FOR EXEMPTION OF

SKY ESTATES DRONES, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

PART 21, SUB PART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a) (1), 91.409(a) (1) & (a) (2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF 3D ROBOTICS SOLO, DJI PHANTOM 2 AND PHANTOM 3 

PROFESSIONAL UNMANNED AIRCRAFT SYSTEMS PURDANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

REQUEST FOR EXEMPTION

Whereas, SKY ESTATE DRONES, LLC (Jimmy Carini) seeks for an exemption seeking relief from the 

requirements OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS. Relief from airworthiness 

certification requirements from the above mentioned regulations.

This exemption will permit SKY ESTATE DRONES, LLC to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography of Real Estate Properties (for 

homeowners, realtors, home builders, home contractors and / or home inspectors for real estate 

marketing and inspection of home exteriors) as well landscape, conducting power line inspection, aerial 

mapping, surveying and search & rescue along with special event production and film and television 

production over certain areas of the United States.
Granting this exemption to SKY ESTATE DRONES, LLC will allow buyers of the real estate market to see 

the viewing property from a different and broader angle, giving the buyer a greater perspective and 

seeing much more potential in a prospective property for sale.

Providing high quality digital imaging and video content to clients, utilizing 3D Robotics Solo, DJI 

Phantom 2 and DJI Phantom 3 Unmanned Aircraft System (UAS).

BACKGROUND INFORMATION

SKY ESTATES DRONES, LLC is based in Tennessee founded in 2015 a Limited Liability Company 

established May 20th 2015 with the Secretary of State Tennessee to specialize in real estate videography 

and photography. ) Providing a topography landscape, and geographical view, conducting power line 

inspection, aerial mapping, surveying and search & rescue along with special event production and film 

and television production. Providing high quality digital imaging and video content and footage to its 

clients, utilizing 3D Robotics Solo, DJI Phantom 2, and DJI Phantom 3 Professional UAV’s.

AERIAL OPERATION INTENTIONS

Sky Estate Drones will be in interest to conduct aerial video and photography of Real Estate Properties 

(for homeowners, realtors, home builders, home contractors and / or home inspectors for real estate 

marketing and inspection of home exteriors and interiors) Providing a topography landscape, and 

geographical view, conducting power line inspection, aerial mapping, surveying and search & rescue

along with special event production and film and television production over certain areas of the United 

States. 

More specifically, SKY ESTATES DRONES, LLC aerial video and photography operations will serve in the 

following areas: 

• Aerial Videography / Photography of Residential, Commercial Buildings and Private Home Owners 

• Aerial Surveys of Land, Geographical Structures and Power Lines

• Aerial Event Videography / Photography

• Aerial Film & Television Production

• Aerial Search & Rescue, along with Safety Inspections

• Increase Public Knowledge of UAS and Promote Safe UAS Operations.

The proposed aerial filming will be conducted over private property with controlled access in the NAS 

and with the knowledge and permit of the private property’s owner.

Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA may grant an 

exemption under 49 U.S.C. §44701(f) if it has determined that such an exemption is in the public 

interest. The FAA has imposed a separate requirement in its procedural regulations, providing that the 

petitioner shall explain why granting the exemption would not adversely affect safety or how the 
exemption would provide at least an equivalent level of safety as compliance with the underlying 

regulation. In this case, approval of this exemption would advance the public interest by significantly 

enhancing the safety and efficiency of market comparable and private events by allowing the UAS to 

accept the liability of the risks involved as the general public would attempt a duplicate result. As 

described more fully below, the requested exemption would permit the operation of UAS under tightly 

controlled conditions, thus ensuring that operations will not have an adverse impact on safety. Granting 

an Exemption is in the Public Interest. The safety and accuracy that the UAS can accept allows the 

general public to avoid potential accidents, both private industry and commercial. It provides a more 

accurate layout so fair market values (FMV’s) may be determined in the lending and marketing process. 

By allowing the UAS to accept these tasks, it allows the general public safety to be greatly reduced and 

allows the property market and industry thrive on a fair and level ground.

By Granting Exemption it will not Adversely Affect Safety

This exemption for SKY ESTATE DRONES, LLC will impact the public by using the 3D Robotics Solo, 

Phantom 2 and the Phantom 3 Professional UA, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

This exemption for SKY ESTATE DRONES, LLC will impact the public by using the 3D Robotics Solo, 

Phantom 2 and the Phantom 3 Professional UA, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric 

motors, rather than an internal combustion engine. 

Granting Exemption to SKY ESTATE DRONES, LLC will enhance safety using UAV’s for videography and 

photography will allow buyers of the real estate market to see the full scope of what they are in the 

market to purchase when viewing property, showing terrain how it actually sets with the structure being 

positioned in the valley or on a hilltop, allowing the view of acreage, crops, ponds, lakes and oceans in 

relative position to the viewing property. Revealing structure that may not be suitable or safe possibly 

leading to restructure later, or even giving one a greater perspective to seeing much more potential in a 

prospective property for sale.

COMPLIANT WITH THE FEDRAL, STATE AND LOCAL LAWS TO FLY UAV’S

SKY ESTATE DRONES, LLC will remain compliant with the federal, state and local laws to fly UAV's. 

Ensuring SKY ESTATE DRONES, LLC does not fly any UAV’s without daylight. SKY ESTATE DRONES, LLC will

not fly UAV’s above 200 feet. The UAV’s will be carried to the site of UAV use. UAV’s will not carry no 

passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft, 

and SKY ESTATE DRONES, LLC will not fly the UAV’s within a congested area or within operations at least 

2 miles from any public airports (including heliports). In the event an operation needs to be conducted 

closer to an airport, SKY ESTATE DRONES, LLC will inform the airport operator and airport air traffic 

control tower of the contemplated operation and will comply with any directions issued by air traffic 

control at that airport. SKY ESTATE DRONES, LLC will stay within the limits of airspeed and not 

exceeding 29 knots (15 m/s), Nor shall any of SKY ESTATE DRONES, LLC fly a UAV weighing more than 55 

lbs. Each UAV will be registered with the FAA and display the proper registration stickers during flight.
These UAV's have a failsafe mode which activates the UAV return to home(RTH) feature so that SKY 

ESTATE DRONES, LLC can ensure they do not get out of the operators control, whether it’s because the 

UAV got out of range, or there was a signal interruption, and or battery on the UAV or controller were 

low. The UAV will activate the RTH feature and return where it started from to ensure public safety of 

the craft. 

Petitioner, SKY ESTATES DRONES, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules 

for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 

3D Robotics Solo, DJI Phantom 2 , and DJI Phantom 3 Professional UAS in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated Sky Estate Drones for 

Exemption Page 7 with the unmanned aircraft and its operation, SKY ESTATES DRONES, LLC operation of 

3D Robotics Solo, DJI Phantom 2 and DJI Phantom 3 Professional UAS meets the conditions of FMRA 

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. 

Accordingly, SKY ESTATES DRONES, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate.

SKY ESTATES DRONES, LLC submits that the requested relief is proper since an equivalent level of safety 

will be ensured. SKY ESTATES DRONES, LLC will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS’s using the methods, techniques, and 

practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and 3D Robotics Solo, 

DJI Phantom 2 Vision and, DJI Phantom 3 Professional Instruction Manual). 

Furthermore, SKY ESTATES DRONES, LLC will document and maintain all maintenance records for the 3D 

Robotics Solo, DJI Phantom 2 Vision and, DJI Phantom 3 Professional UAS. Relief from certain 

requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations:

Pilot In Command, is requested by SKY ESTATES DRONES, LLC to the extent necessary to allow a Pilot 

in Command (PIC) holding a Supplemental Pilot Certificate, and who has demonstrated, by meeting 

minimum flight- hour and currency requirements, that the PIC is able to safely operate the 3D 

Robotics Solo, DJI Phantom 2 Vision and, DJI Phantom 3 Professional UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Sky Estate Drones seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 3D 

Robotics Solo, DJI Phantom 2 Vision and, DJI Phantom 3 Professional UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 
As such, SKY ESTATES DRONES, LLC submits that it will ensure that the 3D Robotics Solo, DJI Phantom 2 

Vision and, DJI Phantom 3 Professional UAS are in an airworthy condition, prior to every flight, by 

determining that the UAS’s are in compliance with the operating documents (i.e., Monthly Maintenance 

Log, and 3D Robotics Solo, DJI Phantom 2 Vision and, DJI Phantom 3 Professional Instruction Manual), 

and that the aircraft are in a condition for safe flight. 

SKY ESTATES DRONES, LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the 3D Robotics Solo, DJI Phantom 2 Vision and, DJI Phantom 3 Professional UAS 

will not have a typical barometric altimeter onboard. 

However, altitude information of the 3D Robotics Solo, DJI Phantom 2 Vision and, DJI Phantom 3 

Professional UA will be provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of 

the flight path. 

This altitude information, combined with SKY ESTATES DRONES, LLC operation of the 3D Robotics Solo, 

DJI Phantom 2 Vision and, DJI Phantom 3 Professional UAS within visual line of sight, at or below 200 

feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, SKY ESTATES DRONES, LLC seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. SKY ESTATES DRONES, LLC submits that safety 

will not be affected by operation of the 3D Robotics Solo, DJI Phantom 2 Vision and, DJI Phantom 3 

Professional UA during daylight hours in visual meteorological conditions (VMC) under visual flight rules 

(VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Minimum requirements for the PIC include:

1) 75 hours of logged UAV Flight Time including still and video capture

 2) Have undergone a qualification process as specified in the Flight Operations

 & Procedures Manual consisting of a knowledge & skill test of the aircraft to be

 used.

 3) Maintain an understanding of all associated pre-flight, in-flight and post flight

 checklists.

SKY ESTATE DRONES, LLC intends to use commercially available UAV Components for UAV.

These UAV systems will be tested for quality & safety before being deployed to the

field. The UAV is less than 55 lbs. fully loaded, carries neither a pilot nor passenger,

and operates exclusively within a secured area. We have a routine maintenance schedule

to verify that the UAV will remain in safe and operational condition.

Please see Appendix B, for Specific Types of UAV.

Notes Regarding: 14 C.F.R. Part 21, Subpart H

In accordance with the statutory criteria provided in Section 333 of PL 112---95 in reference to
49 USC 44704, and in consideration of the size, weight, speed, and limited operating area

associated with the aircraft and its operation, we request that this aircraft exemption meets

the conditions of Section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and

any associated noise certification and testing requirements of part 36, is not necessary.

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft

Given the size of theUAV, two-inch lettering will be impossible. UA will be identified

by serial number, registered in accordance with 14 CFR part 47, and have identification (N-

--Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large

as practicable.

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness

SKY ESTATE DRONES, LLC request is based on the fact that no airworthiness certificate will be

issued for the UAS. SKY ESTATE DRONES, LLC UAV’s will not require an airworthiness certificate

in accordance with 14 CFR part 21, Subpart H. Based on the fact that an airworthiness

certificate will not be issued, exemption from § 91.7(a) is not necessary.

Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard

Certifications required, the original intent of these regulations was to display an aircraft’s

airworthiness, certification, and registration documents so they would be easily available

to inspectors and passengers. Based on the FAA Memorandum subject “Interpretation

regarding whether certain required documents may be kept at an unmanned aircraft’s

control station,” dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b)(2)

and 91.203(a) and (b) is not necessary.

Notes Regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests

Small UASs, by their design, do not have fully functional dual controls. Flight control is

accomplished through the use of a control box that communicates with the aircraft via

radio communications. Aircraft being considered for use by SKY ESTATE DRONES, LLC allow the

UAS Instructor to place the aircraft into ‘loiter’ mode (fixed altitude stationary hold). In

the event of the student losing control, the UAS Instructor can quickly and via alternate

equipment (equipment not in the hands of the student) place the aircraft into a mode that

then allows the instructor to bring the aircraft back into control and back to the predetermined

and/or safe landing location.

SKY ESTATE DRONES, LLC does not describe training scenarios in which a dual set of controls

would be utilized or required, i.e. dual flight instruction, provided by a flight instructor

or other company-designated individual, that would require that individual to have fully

functioning dual controls. Rather, SKY ESTATE DRONES, LLC evaluates the qualification of its PICs

based on their experience with the UAS to be operated and verifies through testing, in

lieu of formalized training. As such, SKY ESTATE DRONES, LLC does not seek relief from 14 CFR §

91.109.

Notes Regarding § 14 CFR 91.119(b)

Relief from § 14 CFR 91.119(b), operation over congested areas, is not applicable,

because SKY ESTATE DRONES, LLC operations will only be conducted within the secured area

described herein.
SKY ESTATE DRONE, LLC Safety Operations & Procedures Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. Software from

highly-reputable industry partners will include features -

1. Auto descent (landing) if communication signal were to be severed. If the UAV

loses communications, the UAV will have capability to return to a pre-determined

location within the Security Perimeter and land.

2. Auto descent (landing) if battery were to drop lower than nominal level.

3. Flights will be terminated at 25% battery power reserve.

4. Live video for operator gives real-time positioning feedback. In other words, we

can monitor the scene from the vehicle's perspective for collision avoidance, and to

maintain spatial orientation.

5. The UAV will have the capability to abort a flight in case of unpredicted obstacles

or emergencies.

6. On-Screen-Display (OSD) contains operating information to ascertain vehicle

health at all times: speed, altitude, number of GPS satellites (when available),

heading and voltage.

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2)

link failures occur (highly improbable), vehicle returns automatically to the point of

launch.

8. Altitude information will be provided to the UAV pilot via a digital coded

telemetric data feed, which downlinks from the aircraft to a ground-based on-screen

display. This altitude information will be generated by equipment installed on board

the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or

radio altimeter, or any combination thereof. Prior to each flight, a zero altitude

initiation point will be established and confirmed for accuracy by the pilot.

Mechanical/Physical:

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in direct LOS

to the pilot, thus eliminating the concern of signal severance (flying behind

objects/walls).

2. The sUAS will weigh less than 55 lbs and travel at less than 50 knots.

3. Batteries should far exceed the capacity required for actual flight time.

4. Flights will be operated at an altitude of no more than 200 feet AGL.

5. Fireproof bags for storage and charging of high capacity Lipo batteries on-site.

6. UA operated under this exemption will be marked in accordance with 14 CFR

part 45 or as otherwise authorized by the FAA.

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for operators

(pilot, gimbal op, director)
2. Radio spectrum analysis for interference on the frequencies utilized for vehicle

control/communication.

3. A briefing will be conducted in regard to the planned UAV operations prior to

each day’s activities. It will be mandatory that all personnel who will be performing

duties within the boundaries of the safety perimeter be present for this briefing.

4. The operator will obtain the consent of all persons involved in the UAV operations

and ensure that only consenting persons will be allowed within 100 feet of the flight

operations.

5. Observer and pilot will at all times be able to communicate by voice.

6. Written and/or oral permission from the relevant property holders will be obtained.

7. Pilot and observer will have been trained in operation of UAV generally and

received up-to-date information on the particular UAV to be operated.

Operations:

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg),

including energy source(s) and equipment. Operations authorized by this petition

of exemption are limited to the following aircraft described in Appendix B.

Proposed operations of any other aircraft will require a new petition or a petition

amendment to this request.

2. The UA may not be flown at a ground speed exceeding 50 knots.

3. Flights must be operated at an altitude of no more than 200 feet above ground

level (AGL), as indicated by the procedures specified in the operator’s manual.

All altitudes reported to ATC must be in feet AGL.

4. The UA must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any device

other than corrective lenses, as specified on the PIC’s State issued identification

license.

5. All operations must utilize a visual observer (VO). The VO may be used to

satisfy the VLOS requirement as long as the PIC always maintains VLOS

capability. The VO and PIC must be able to communicate verbally at all times.

6. The operator’s manual included as Appendix C and this petition of exemption

must be maintained and made available to the Administrator upon request. If a

discrepancy exists between the conditions and limitations in this exemption and

the procedures outlined in the operator’s manual, the conditions and limitations

herein take precedence and must be followed. Otherwise, the operator must

follow the procedures as outlined in its operator’s manual.
The operator may update or revise its operator’s manual. It is the operator’s

responsibility to track such revisions and present updated and revised documents

to the Administrator upon request. The operator must also present updated and

revised documents if it petitions for extension or amendment. If the operator

determines that any update or revision would affect the basis for which the FAA

grants this petition for exemption, then the operator must petition for amendment

to their exemption. The FAA’s UAS Integration Office (AFS-80) may be

contacted if questions arise regarding updates or revisions to the operator’s

manual.

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition

for safe flight. If the inspection reveals a condition that affects the safe operation

of the UAS, the aircraft is prohibited from operating until the necessary

maintenance has been performed and the UAS is found to be in a condition for

safe flight. The Ground Control Station, if utilized, must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical component,

must undergo a functional test flight in accordance with the operator’s manual.

The PIC who conducts the functional test flight must make an entry in the UAS

aircraft records of the flight. The requirements and procedures for a functional test

flight and aircraft record entry must be added to the operator’s manual.

9. The operator must follow the manufacturer’s UAS aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

When unavailable, aircraft maintenance/component/overhaul, replacement, and

inspection/maintenance requirements must be established and identified in the

operator’s manual. At a minimum, requirements for the following must be

included in the operator’s manual:

a. Actuators / Servos;

b. Transmission (single rotor);

c. Powerplant (motors);

d. Propellers;

e. Electronic speed controller;

f. Batteries;

g. Mechanical dynamic components (single rotor);

h. Remote command and control;

i. Ground control station (if used); and

j. Any other components as determined by the operator;

10. The Pilot In Command (PIC) Must have logged the required information as

set previous in the minimum requirements for a PIC
11. During training, proficiency, and experience-building flights, all persons not

essential for flight operations are considered nonparticipants, and the PIC must

operate the UA with appropriate distance from nonparticipants in accordance with

14 CFR § 91.119.

12. Prior to operations conducted for the purpose of infrastructure inspection, the

PIC must have accumulated and logged, in a manner consistent with 14 CFR §

61.51(b), a minimum of five hours as UAV pilot operating the make and model of

UAV to be utilized for operations under the exemption and three take-offs and

three landings in the preceding 90 days. 

Training, proficiency, experience building,

and take-off and landing currency flights can be conducted under this

petition of exemption to accomplish the required flight time and 90 day currency.

During training, proficiency, experience-building, and take-off and landing

currency flights all persons not essential for flight operations are considered

nonparticipants, and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this petition of exemption, the PIC

and VO must have successfully completed a qualification process, as outlined in

the operator’s manual. As this is a requirement stipulated by the operator, the test

must be developed and implemented by a qualified person designated at the sole

discretion of the operator. A record of completion of this qualification process

must be documented and made available to the Administrator upon request.

14. Prior to operations conducted for the purpose of infrastructure inspection, a flight

demonstration, administered by an operator-approved and -qualified pilot must be

successfully completed and documented. This documentation must be available for

review upon request by the Administrator. Because the knowledge and airmanship

test qualifications have been developed by the operator, and there are no established

practical test standards that support a jurisdictional FAA FSDO evaluation and

approval of company designated examiners, the petitioner will conduct these tests in

accordance with the operator’s manual.

15. The UA may not be operated directly over any person, except authorized

And consenting personnel, below an altitude that is hazardous to persons or property on

the surface in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has

safety mitigations for authorized and consenting personnel. At all times,

those persons must be essential to the operations.

Regarding distance from nonparticipating persons, the operator must ensure that no

persons are allowed within 500 feet of the area except those consenting to be
involved and necessary for the flight path operations. 

This provision may be reduced

to no less than 200 feet if it would not adversely affect safety and the Administrator

has approved it. For example, an equivalent level of safety maybe determined by an

aviation safety inspector’s evaluation of flight path area to note terrain features,

obstructions, buildings, safety barriers, etc.

Such barriers may protect

nonparticipating persons (observers, the public, news media, etc.) from debris in the

event of an accident.

17. If the UAS loses communications or loses its GPS signal, the UA must return to a

pre-determined location within the security perimeter and land or be recovered in

accordance with the operator’s manual.

18. The UAS must abort the flight in the event of unpredicted obstacles or

emergencies in accordance with the operator’s manual.

19. Each UAS operation must be completed with 25% battery power remaining.

20. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of

Waiver or Authorization (COA) prior to conducting any operations under this petition

of exemption. 

This COA will also require the operator to request a Notice to Airman

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the

operation.

21. All aircraft operated in accordance with this exemption must be identified by

serial number, registered in accordance with 14 CFR part 47, and have identification

(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must

be as large as practicable.

22. The operator must develop procedures to document and maintain a record of the

UAS maintenance, preventative maintenance, alterations, status of

replacement/overhaul component parts, and the total time in service of theUAS.

These procedures must be added to the operator’s manual.

23. Each UAS operated under this exemption must comply with all manufacturer

Safety Bulletins.

24. The operator must develop UAS technician qualification criteria. These criteria

must be added to the operator’s manual.

25. The preflight inspection section in the operator’s manual must be amended to

include the following requirement: The preflight inspection must account for all

discrepancies, i.e. inoperable components, items, or equipment, not covered in the

relevant preflight inspection sections of the operator’s manual.
26. Before conducting operations, the radio frequency spectrum used for operation

and control of the UA must comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.

27. At least three days before scheduled UAV flight as contracted by any party, the

operator of the UAS affected by this exemption must record a plan of activities. The

plan of activities must include at least the following:

a) Dates and times for all flights;

b) Name and phone number of the operator for the UAS operations conducted under this

 petition of exemption;

c) Name and phone number of the person responsible for the on-scene operation of the

 UAS;

d) Make, model, and serial or N-number of UAS to be used;

e) Name UAS PICs involved in the flight event;

f) A statement that the operator has obtained permission from property owners and/or

 local officials to conduct the infrastructure inspection event; the list of those who

 gave

 g) Signature of exemption-holder or representative; and

 h) permission must be made available to the inspector upon request;

 i) A description of the flight activity, including maps or diagrams of any area, city, town,

 county, and/or state over which flight path willbe conducted and the altitudes

 essential to accomplish the operation.

28. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to

the PIC at the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law

enforcement official upon request.

29. The UA must remain clear and yield the right of way to all other manned

operations and activities at all times (including, but not limited to, ultralight vehicles,

parachute activities, parasailing activities, hang gliders, etc.).

30. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1.

All operations must be conducted under visual meteorological conditions(VMC).

Flights under special visual flight rules (SVFR) are not authorized.

31. The UAS may not be operated by the PIC from any moving device or vehicle.

32. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

33. The UA may not operate in Class B, C, or D airspace without written approval
from the FAA. The UA may not operate within 5 nautical miles of the geographic

center of a non-towered airport as denoted on a current FAA-published aeronautical

chart unless a letter of agreement with that airport’s management is obtained, and the

operation is conducted in accordance with a NOTAM as required by the operator’s

COA. The letter of agreement with the airport management must be made available to

the Administrator upon request.

34. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported

to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be

reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not

be conducted until the incident, accident, or transgression is reviewed by AFS-80 and

authorization to resume operations is provided.

Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, SKY ESTSATE DRONES, LLC

provides the following information:

Contact Information:

SKY ESTATE DRONES, LLC

Jimmy Carini

229 Hillside Rd

Oak Ridge TN, 37830

865-385-2132

skyestatedrones@gmail.com

Regulatory Provisions from which SKY ESTATE DRONES, LLC

seeks an Exemption

SKY ESTATE DRONES believes it may need an exemption from the following provisions

to conduct the contemplated operations. In some instances, relief is needed because relief

from another provision renders compliance with the regulation at hand infeasible.

333 Aircraft Exemption Status

14 C.F.R. §61.113(a) and (b)

14 C.F.R. §91.119(c)

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)(1)&(2)

14 C.F.R. §91.417(a)&(b)

SKY ESTATE DRONES, LLC believes an exemption is only needed from the above-listed

regulatory provisions. To the extent that the FAA believes that additional relief is

required for SKY ESTATE DRONES, LLC to conduct the operations described here, we request an

exemption from any such regulatory provisions as well.3

3 For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as

applicable”. Since none of the underlying requirements (e.g., inspection intervals) can be met and will
require an exemption, SKY ESTATE DRONES believes a separate exemption should not be required 

for§91.417(a).

The Extent of Requested Relief and the Reasons Relief is Needed

Section 333 Aircraft Exemption Status:

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the

requirement for an airworthiness certificate based on a consideration of the size, weight,

speed, operational capability of the particular UAS, as well as its proximity to airports and

populated areas. An analysis of these criteria demonstrates that the UAV operated without an

airworthiness certificate in the areas and under the conditions contemplated by

SKYCAPTURE will be at least as safe, or safer, than a conventional aircraft (fixed wing or

rotorcraft) operating with an airworthiness certificate without the conditions proposed in this

request.

The UAV is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and operates

exclusively within a secured area. Unlike other civil aircraft, operations under this exemption

will be tightly controlled and monitored by the operator and observer. Operations will be

conducted in compliance with the FAA and with local public safety requirements to provide

security for the area of operation as is now done with conventional equipment, infrastructure,

bridge and out building evaluation. These safety enhancements provide an expanded degree

of safety to the inspectors over conventional operations. Lastly, application of these same

criteria demonstrates that there is no credible threat to national security posed by the UAV,

due to its size, speed of operation, location of operation, lack of explosive materials and

inability to carry a substantial external load.

Given the size and limited operating area associated with the aircraft to be utilized by the

Applicant, this meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the

requirement for an airworthiness certificate, upon consideration of the size, weight,

speed, operational capability, and proximity to airports and populated areas of the

particular UAV. In all cases, an analysis of these criteria demonstrates that the UAV

operated without an airworthiness certificate, in the restricted environment and under the

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and

conditions proposed.14 C.F.R. §61.113(a) and (b)

§61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person

who holds a private pilot certificate may act as pilot in command of an aircraft

that is carrying passengers or property for compensation or hire; nor may that

person, for compensation or hire, act as pilot in command of an aircraft.
(b) A private pilot may, for compensation or hire, act as pilot in command of

an aircraft in connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

 (2) The aircraft does not carry passengers or property for compensation or

 hire.

SKY ESTATE DRONES, LLC anticipates initially using a cadre of specially trained staff to

conduct the UAV operations. While these individuals will not hold commercial pilot

licenses. The UAV will not carry property for compensation or hire since they will be

used solely to assist in evaluation of market comparable for real estate purposes and

private party contracts; however, the employees’ operation of the UAV will not be

incidental to their employment with SKY ESTATE DRONES, LLC, and they will be compensated for

such work. Without an exemption, the pilot would be required to hold a commercial pilot

certificate under §61.133. However, the risk associated with the contemplated operations

is less than the risk posed by a traditional aircraft. The UAV will fly at altitudes well

below the permissible limits for other civil aircraft, eliminating the risk to other aircraft,

and within a geographical envelope under the sole control of SKY ESTATE DRONES, LLC clients.

Accordingly, the risk would be limited to SKY ESTATE DRONES, LLC personnel, who will be

appropriately outfitted in safety gear, and SKY ESTATE DRONES, LLC client’s property on the

ground. Requiring a commercial pilot certificate would provide no appreciable safety

benefit and would needlessly impose additional cost on SKY ESTATE DRONES, LLC. Because the

contemplated operations would not comply with §61.113(b)(1) and none of the other

exceptions to paragraph (a) apply, relief is needed from both paragraphs (a) and (b).

14 C.F.R. 91.119(c)

§91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an

aircraft below the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface,

except over open water or sparsely populated areas. In those cases, the aircraft

may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

SKY ESTATE DRONES, LLC submits that the only relief it requires from §91.119 is from the

minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed

wing operations because asset evaluation conducted at 500 feet or higher is insufficiently

distinct to be meaningful. Since operations at this altitude also pose a heightened risk of

collision with another aircraft, safety can only be assured through the grant of an

exemption. The anticipated rotorcraft operations should be adequately addressed by

paragraph (d) (1). Additionally, relief should not be needed from paragraph (a) because

an emergency landing of the aircraft due to a power failure will not create an undue

hazard to persons or property on the surface. As noted in the explanation of why an

exemption will not adversely affect safety, SKY ESTATE DRONES, LLC clients has exclusive use of
the land over which the sUAS will be operated, and public access is restricted. It also has

exclusive use of significant portions of land adjacent to the infrastructure and structures

that will be the objects of evaluation and analysis. SKY ESTATE DRONES, LLC Clients tightly

control access to land and have the ability to assure that no individuals unassociated with

the planned operations are on the affected land. As such, the risk of injury is minimal.

SKY ESTATE DRONE, LLC does not contemplate conducting operations over congested areas, so

relief is not requested from paragraph (b).

14 C.F.R. 91.121

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising

altitude by reference to an altimeter that is set “...to the elevation of the departure

airport or an appropriate altimeter setting available before departure.”

As the UAV may not have a barometric altimeter, but instead a GPS altitude read

out, an exemption may be needed. An equivalent level of safety will be achieved by the

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the

launch site shown on the GPS altitude indicator before flight.

Altitude information will be provided to the UAV pilot via a digitally encoded telemetric

data feed, which downlinks from the aircraft to a ground-based on-screen display. This

altitude information will be generated by equipment installed on board the aircraft, using

GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any

combination thereof. Prior to each flight, a zero altitude initiation point will be established

and confirmed for accuracy by the pilot.

14 C.F.R. 91.151

§91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed –

During the day, to fly after that for at least 30 minutes.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(Considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed, to

fly after that for at least 20 minutes.

Operating the UAV in a pre-defined area with less than 30 minutes of reserve

fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could

run out of fuel in the event it has to be flown to an alternate airport or circle the planned

airport in the event of unanticipated conditions.

SKY ESTATE DRONES, LLC does not intend to use the UAV for point-to-point flights and will not operate

the UAV beyond visual line of sight. Nor will the UAV require an airport in order to land. 
Rather, SKY ESTATE DRONES, LLC will operate the UAV using pre-planned flight paths (taking into 

account weather conditions) designed to allow the UAV to fly to the point of intended landing. As such, 

there is no need for a time- based excess fuel requirement. Rather it should be sufficient to require

only as much additional excess flight capacity as necessary to safely land the UAV. 

We believe that a 25% battery reserve is more than sufficient to meet this objective.

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b)

§91.405 Maintenance required.

Each owner or operator of an aircraft –

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and

shall between required inspections, except as provided in paragraph (c) of this

section, have discrepancies repaired as prescribed in part 43 of this chapter;

§91.407 Operation after maintenance, preventive maintenance,

rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance,

rebuilding, or alteration unless –

(1) It has been approved for return to service by a person authorized under

§43.7 of this chapter;

§91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate

an aircraft unless, within the preceding 12 calendar months, it has had

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by §43.7 of this

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in

accordance with part 21 of this chapter.

§91.417 (a) & (b)

SKY ESTATE DRONES, LLC believes that an exemption from these three maintenance

requirements is appropriate because the FAA has not developed maintenance standards

that would allow an operator to meet the part 91 maintenance requirements. In particular,

there are no individuals authorized by the FAA to approve a UAV for return to service

under §91.407(a) or to conduct the initial airworthiness and annual return to service inspections

required by §91.409(a). 

SKY ESTATE DRONES, LLC will maintain the aircraft as instructed in the

owner’s manual and ASTM F2909, where applicable, and will not operate the aircraft

until it has reasonably determined that any needed repairs have been made. However,

because of the technical impossibility of meeting the requirements of §§91.405(a),
407(a), 409(a) and 417(a)&(b), we believe an exemption from these provisions is

appropriate.

Please do not hesitate to contact me at the phone number or via the e-mail address

provided above should you have any questions or concerns.

Appendix A

Summary for Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register should the FAA determine that publication is needed.

Petitioner: Jimmy Carini SKY ESTATE DRONES, LLC

Sections of 14 C.F.R. Affected:

333 Aircraft Exemption Status

14 C.F.R. §61.113(a) and (b)

14 C.F.R. §91.119(c)

14 C.F.R. §91.121

14 C.F.R. §91.151

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)

14 C.F.R. §91.409(a)

14 C.F.R. §91.417(a)&(b)

Description of Relief Sought:

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14

C.F.R., 61.113(a)&(b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), and

91.417(a)&(b) to conduct UAV operations over SKY ESTATE DRONES, LLC Client’s owned or

controlled land, solely during daylight hours, to assist in the safe evaluation and analysis

of infrastructure and operations. In general, UAV operations are intended to be

conducted in areas remote from both congested areas and airports. The nature of

operations anticipated by SKY ESTATE DRONES, LLC requires that the UAV be flown at relatively

low altitudes SKYCAPTURE expects that in most instances, the UAV will be flown less

than 75 feet from the highest structure along the path of the UAV and in no instances

will be flown higher than 200 feet above the ground. Accordingly, the risk of interference

with other aircraft is minimal.

Appendix B

UAV’s to be operated and registered by FAA for the commercial use by SKY ESTATE DRONES, LLC

1) 3D Robotics Solo
The 3D Robotics Solo specifications:

Cameras: Compatible with GoPro® HERO3, 3+ and 4; optimized for HERO3+ and 4

Streaming video quality: 720p

Flight time: 25 minutes; 20 minutes with payload*

Range: .5 miles** (.8 km)

Max speed: 55 mph (89 km/h)

Max ascent speed: 10 m/s in stabilize mode; “fly” mode spec forthcoming

Max descent speed: ditto

Max payload: 420 g

Max altitude: 400 ft per FAA regulation, user adjustable (122 m)

Motors: 880 kV

Propellers: 10ʺ diameter 4.5ʺ pitch self-tightening (24 cm diameter 144 cm pitch)

Autopilot: Pixhawk 2

Software: APM:Copter

Communication: 3DR Link secure WiFi network

Frequency: 2.4 GHz

Weight: 3.3 lbs. (1.5 kg) / 3.9 lbs. (1.8 kg) with GoPro® and Solo Gimbal

Dimensions: 10 in. tall (25 cm), 18 in. (46 cm) motor-to-motor

Flight battery: Lithium polymer 5200 mAh 14.8 Vdc

Battery charge time: ~1.5 hours

Controller battery: 2600 mAh 7.2 Vdc rechargeable lithium ion

App requirements: iOS 8.0 or later / Android 4.3 or later
Solo Gimbal:

Three-axis stabilization

Compatible with 3DR Solo and GoPro HERO3+ and HERO4

HDMI video output

Wireless software upgrade through Solo

Controllable range: 0° to -90° pitch

2) Phantom 3 Professional

The DJI Phantom 3 Professional specifications:

UAV

Weight (Battery & Propellers Included 1280 g

Diagonal Size ( including propellers) 590 mm

Max. Ascent Speed 5 m/s

Max. Descent Speed 3 m/s

Hover Accuracy - Vertical: + / - 0.1 m (when vision positioning is active) or + /- 0.5 

- Horizontal + /- 1.5 m

Max. Speed 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level 6000 m

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

CAMERA Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M

 Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞
 ISO Range 100-3200 (video) 100-1600 (photo)

 Shutter Speed 8s -1/8000s

 Image Max Size 4000 x 3000

 Still Photography Modes - Single Shot

 - Burst Shooting: 3/5/7 shots

 - Auto Exposure Bracketing (AEB): 3/5

 - Bracketed Frames at 0.7EV Bias

 - Time-lapse

 Video Recording Modes - UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 - FHD: 1920x1080p 24/25/30/48/50/60

 - HD: 1280x720p 24/25/30/48/50/60

 Supported SD Card Types - UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 - FHD: 1920x1080p 24/25/30/48/50/60

 - HD: 1280x720p 24/25/30/48/50/60

 Max Bit Rate of Video Storage 60 Mbps

 Supported File Formats FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG-4 AVC/H.264)

 Operating Temperature 0°C to 40°C

GIMBOL Controllable Range Pitch -90° to +30°

 Stabilization 3-axis (pitch, roll, yaw)

Vison Positioning Max Velocity c Less than 8 m/s (when 2 m above ground)

 Altitude Range 30 cm-300 cm

 Operating Range 30 cm-300 cm
 Operating Environment Surface with clear pattern and adequate lighting (Lux > 15)

Remote Controller Operating Frequency 2.400 GHz-2.483 GHz

 Max Distance 2000m (outdoors and unobstructed)

 Video Output Port USB

 Operating Temperature 0°C to 40°C

 Battery 6000 mAh LiPo 2S

 Mobile Device Holder For tablet or smart phone

 Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

 Transmitter Power (EIRP) FCC: 20 dBm

 CE: 16 dBm

 Working Voltage 1.2A@7.4 V

Battery Charger Voltage 17.4 V

 Rated Power 100 W

 Capacity 4480 mAh

 Voltage 15.2 V

 Battery Type LiPo 4S

 Energy 64 W

 Net Weight 356g

 Max Flight Time Approximately 23 minutes

 Operating Temperature -10°C to 40°C

 Max Charging Power 100 W

App / Live View Mobile App DJI Pilot

 EIRP 100 mW

 Live View Working Frequency 2.4GHz ISM

 Live View Quality 720P @ 30fps (depending on conditions and mobile device)

 Latency 220ms (depending on conditions and mobile device)

 Required Operating Systems IOS 8.0 or Later

 Android 4.1.2 or Later

 Recommended Devices iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air

 Wi-Fi + Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular,

 iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad

 mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s

 , iPhone 6, and iPhone 6 Plus

 Android: Samsung S5, Note 3, Sony Xperia Z3, Google

 Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini

 *Support for additional Android devices available as
 testing and development continues

 

Phantom 2

The DJI Phantom 2 specifications:

Aircraft operating environment temperature -10°C to 50°C

Power consumption 5.6W

Supported Battery DJI Intelligent battery 

Weight (including the battery) 1000g 

Take-off Weight ≤1300g 

Hovering Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m 

Max Yaw Angular Velocity 200°/s 

Max Tilt Angle 35° 

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s 

Max Flight Speed 15m/s (Not Recommended) 

Wheelbase 350mm 

2.4GHz Remote Controller Operating

Frequency 2.4GHz ISM 

Communication Distance (open area) 1000m 

Receiver Sensitivity (1%PER) -97dBm 
Working Current/Voltage 120 mA@3.7V 

Built-in LiPo Battery Working Current/Capacity 3.7V, 2000mAh

DJI Intelligent Battery

Type 3S LiPo Battery

Capacity 5200mAh, 11.1V 

Charging Environment Range 0°C to 40°C

Discharging Environment Range -20°C to 50°C

Appendix C

***PDF Files Attached***

3D Robotics SOLO Manual

Phantom 3 Professional Manual

Phantom 2 Manual